Success for civil society: Major German bank distances itself from deep-sea mining

This blog was written by Luca Schiewe of Fair Finance Germany coalition member Facing Finance .

On January 29, 2026, Commerzbank, Germany’s third-largest bank by total assets, published its first-ever policy on deep-sea mining.

The deep sea is one of the last largely unexplored ecosystems on Earth. It is home to unique species, many of which we barely understand. However, several companies are currently preparing to search the deep sea for raw materials, despite enormous scientific uncertainty about the environmental impacts. Studies show that deep-sea mining (DSM) activities can cause irreversible damage to ecosystems that are important for the climate and biodiversity. Once destroyed, the deep sea may not recover within human timescales.

DSM could cause irreversible damage:
- Destruction of fragile ecosystems and biodiversity
- Release of toxic substances into marine habitats
- Sediment plumes that suffocate marine life
- Disruption of global CO₂ storage processes

Banks play a crucial role in determining which activities are financed and which are not. Yet most banks have so far adopted no policies against deep-sea mining. As a result, they can finance companies involved in such activities without any conditions.

Since January 29, 2026, Commerzbank has publicly clarified that it does not finance deep-sea mining projects. It also excludes general corporate loans to companies that operate exclusively in DSM. We welcome this public positioning by Commerzbank. However, in our view there is still room for improvement: general corporate loans to companies that are involved in DSM among other activities remain possible. We therefore call on banks to exclude general corporate loans to companies with links to DSM. Instead, such companies should at most receive earmarked financing that cannot be used for DSM activities.

Specifically, the new ESG framework of Commerzbank states on page 18: “Until further notice, Commerzbank will not participate in the financing of deep-sea mining projects and will not enter into business relationships with companies that are exclusively active in deep-sea mining (so-called pure-play companies).”

The fact that Commerzbank has now publicly positioned itself against DSM for the first time is a success of civil society engagement. In 2025, the Fair Finance Guide Germany together with DSM Campaign and Ozeanien-Dialog, drew Commerzbank’s attention to DSM. This included an engagement letter sent to Commerzbank as well as a meeting where the social, environmental, and financial risks of DSM were presented and jointly discussed with Commerzbank employees. The Fair Finance Guide Germany also launched a “Write to Your Bank!” campaign in which Fair Finance Guide users urged their banks not to finance deep-sea mining. You can still select your bank here and send it a pre-written mail opposing DSM.

German banks now seem to be slowly waking up and addressing the risks of DSM. In September 2024, Deutsche Bank had already published a policy excluding the direct financing of DSM projects. However, general corporate loans to companies active in DSM remain possible. For example, a company like the DEME Group with its deep-sea exploration subsidiary Global Sea Mineral Resources (GSR) can still receive general corporate loans. Investors in the DEME Group include Deutsche Bank and DZ Bank, while Deutsche Bank, DekaBank, and ING invest in DEME’s majority owner Ackermans & Van Haaren.

Overall, the Fair Finance Guide Germany has identified financial relationships (loans or investments in shares/bonds) for eight banks analyzed in the Fair Finance Guide Germany with seven companies that are active, among other things, in DSM. These eight banks are Deutsche Bank, DZ Bank, DekaBank, ING, UniCredit, Commerzbank, BayernLB, and LBBW. The seven companies are DEME Group, Ackermans & Van Haaren, CMRELTD, Bosch Ltd, Bauer, Continental, and Noble Corporation.

Even though some banks, most recently Commerzbank, are now positioning themselves against DSM, there is still significant room for improvement. Too many banks still do not have DSM on their radar. We hope that more banks will follow Commerzbank’s example and publicly oppose DSM.

We demand: Banks must take responsibility!

❌ No direct financing of DSM projects
❌ No general corporate loans to companies with links to DSM

✅ Clear and transparent criteria for investments and financing

✅ Only earmarked financing that cannot be used for DSM activities

✅ Shareholder engagement (active dialogue with companies) to prevent DSM expansion

📣 Tell your bank: Our oceans are too valuable to gamble with!

Click here, choose your bank, and send a pre-written message calling for a clear DSM policy. It only takes a few seconds, but together we can make a difference. So that banks fulfill their role in protecting our oceans.